gdpr policy - marico marine

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GDPR POLICY

Issue: 04 Date: 29 April 2021

Commercial-in-Confidence Issue No: 04 GDPR POLICY

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Written By:

Checked By:

André Cocuccio

Shirley Barnet

Date Release Prepared Authorised Notes

01-05-2020 02 AC SB Superseded

23-09-2020 03 AC AC Final

Marine and Risk Consultants Ltd

Marico Marine, Bramshaw, Southampton

SO43 7JB Hampshire, United Kingdom

Tel. + 44 (0) 2380 811133


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CONTENTS

1 Introduction .................................................................................................................................. 4

2 Compliance .................................................................................................................................... 4

3 Responsibility ................................................................................................................................ 5

4 Data Protection Principles ............................................................................................................. 6

4.1 Process Personal Data Fairly And Lawfully (The Right To Be Informed) ............................. 6

4.2 Subject Access Rights (SARS) (The Right Of Access) ........................................................... 6

4.3 Keep Personal Data Accurate (The Right To Rectification). ................................................ 7

4.4 Only Keep Personal Data For As Long As Is Necessary (The Right To Erasure). ................. 7

4.5 Restrict The Process Of Personal Information. ................................................................... 7

4.6 Ensure That No Personal Data Is Transferred To A country Or A Territory Outside Of The United Kingdom (UK) .................................................................................................................... 7

4.7 The Right To Object ............................................................................................................ 8

5 Incident ......................................................................................................................................... 8


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1 INTRODUCTION

Marico Marine is committed to a policy of protecting the rights and privacy of individuals, in

accordance with the General Data Protection Regulation (GDPR). GDPR contains provisions that the

organisation will need to be aware of as data controllers, including provisions intended to enhance the

protection of personal data.

GDPR requires that:

Marico Marine needs to process certain information about its staff, customer, suppliers, and other

individuals with whom it has a relationship for various purposes such as, but not limited to:

▪ The recruitment and payment of staff;

▪ The day to day purchasing and sales of goods;

▪ The making or receiving of payments as part of day to day trading;

▪ Contacting you about a submission or request for information you have made;

▪ Contacting you in relation to any correspondence we receive from you or any comment or

complaint you make about our products or services; and

▪ Complying with legal obligations and government including local government.

To comply with various legal obligations, including the obligations imposed on it by GDPR, Marico

Marine must ensure that all this information about individuals is collected and used fairly, stored safely

and securely, and not disclosed to any third party unlawfully.

2 COMPLIANCE

All members of staff are responsible for ensuring that any personal information which they hold is kept

securely and not disclosed to any unauthorised third parties. Marico Marine will ensure that all

personal information is accessible only to those who have a valid reason for using it. Marico Marine

will have in place appropriate security measures to protect information physically and electronically.

As a matter of best practice, other agencies and individuals working with Marico Marine and who have

access to personal information, will be expected to read and comply with this policy. It is expected that

departments who are responsible for dealing with external bodies will take the responsibility for

ensuring that such bodies sign a contract which, among other things, will include an agreement to

abide by this policy.


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Consent as a basis for processing information, although not always necessary, is the best way to ensure

that information is collected and processed in an open and transparent manner. Consent is especially

important when Marico Marine is processing any sensitive information, as defined by the legislation.

Marico Marine understands consent to mean that the individual has been fully informed of the

intended processing and has signified their agreement. Marico Marine also confirms consent cannot

be inferred from the non-response to a communication.

This policy will be updated as necessary to reflect best practice in information management, security,

and control and to ensure compliance with any changes or amendments to the GDPR and other

relevant legislation. This policy applies to all staff of Marico Marine. Any breach of this policy or of the

Regulation itself will be considered an offence and the company’s disciplinary procedures may be

invoked.

3 RESPONSIBILITY

Responsibilities under GDPR mean that Marico Marine will be the ‘data controller’ under the terms of

the legislation. This means it is ultimately responsible for controlling the use and processing of personal

data. The company appoints a Data Protection Officer (DPO) for each site who is available to address

any concerns regarding the data held by the company and how it is processed, held, and used.

The Senior Management Team is responsible for all day-to-day data protection matters and will be

responsible for ensuring that all members of staff and relevant individuals abide by this policy, and for

developing and encouraging good information handling within the company.

The Senior Management Team is also responsible for ensuring that the Company’s policy is kept up to

date. Details of the Marico Marine’s policy can also be found on their website.

Compliance with the legislation is the personal responsibility of all staff at Marico Marine who process

personal information.

Individuals who provide personal data to Marico Marine are responsible for ensuring that the

information is accurate and up-to-date.


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4 DATA PROTECTION PRINCIPLES

4.1 PROCESS PERSONAL DATA FAIRLY AND LAWFULLY (THE RIGHT TO BE INFORMED)

Marico Marine will make all reasonable efforts to ensure that individuals who are the focus of Personal

Identifying Information (PII) are informed of the identity of the data controller, the purposes of the

processing, any disclosures to third parties that are envisaged, given an indication of the period for

which the data will be kept, and any other information which may be relevant.

The Company will ensure that the data is adequate, relevant and not excessive in relation to the

purpose for which it is processed. Marico Marine will not seek to collect any personal data which is not

strictly necessary for the purpose for which it was obtained.

The Company will process the data for the specific and lawful purpose for which it was collected and

not further process the data in a manner incompatible with this purpose. The Company will ensure

that the reason for which it collected the data originally is the only reason for which it processes that

data unless the individual consents to any additional processing before it takes place.

Marico Marine undertakes not to disclose personal data to unauthorised third parties. Legitimate

disclosures may occur in the following instances:

▪ Where the individual has given their consent to the disclosure; and

▪ The disclosure is required for the performance of a contract.

There are other instances when the legislation permits disclosure without the consent of the individual.

CCTV. There are some CCTV systems operating at Marico House for the purpose of protecting staff

and property. Marico Marine will only process personal data obtained by the CCTV system in a manner

which ensures compliance with the legislation.

4.2 SUBJECT ACCESS RIGHTS (SARS) (THE RIGHT OF ACCESS)

Individuals have a right to access any personal data relating to them which is held by Marico Marine.

We will use reasonable efforts consistent with our legal duty to supply, correct or delete personal

information about you on our files.

Any individual wishing to exercise this right should apply in writing to the Data Protection Officer.

Any member of staff receiving a SAR should forward this to the Data Protection Officer.

To ensure security we require you to prove your identity with 2 pieces of approved identification

before any SARs request can be released.


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4.3 KEEP PERSONAL DATA ACCURATE (THE RIGHT TO RECTIFICATION).

It is the responsibility of the individuals giving their personal data to ensure that this is accurate, and

everyone should notify the Company if a change in circumstances means that the data needs to be

updated.

It is the responsibility of the Company to ensure that any notification regarding the change is noted

and acted on.

4.4 ONLY KEEP PERSONAL DATA FOR AS LONG AS IS NECESSARY (THE RIGHT TO

ERASURE).

Marico Marine undertakes not to retain personal data for longer than is necessary to ensure

compliance with GDPR legislation, and other statutory requirements. This means Marico Marine will

undertake a periodic review of the information held and implement a purge process as required.

Marico Marine will dispose of any personal data in a way that protects the rights and privacy of the

individual concerned.

4.5 RESTRICT THE PROCESS OF PERSONAL INFORMATION.

Individuals have the right to prevent processing of information while that information is subject to

corrective action

At any time, a person can request to know what information is stored and request action to rectify,

block, erase or destroy inaccurate information while that process is underway.

4.6 ENSURE THAT NO PERSONAL DATA IS TRANSFERRED TO A COUNTRY OR A TERRITORY

OUTSIDE OF THE UNITED KINGDOM (UK)

Unless that country or territory ensures an adequate level of protection for the rights and freedoms of

data subjects in relation to the processing of personal data. Marico Marine will not transfer data to

such territories without the explicit consent of the individual. This also applies to publishing

information on the Internet - because transfer of data can include placing data on a website that can

be accessed from outside the UK - so Marico Marine will always seek the consent of individuals before

placing any personal data (including photographs) on its website.

If Marico Marine collects personal data in any form via its website, it will provide a clear and detailed

privacy statement prominently on the website, and wherever else personal data is collected.


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4.7 THE RIGHT TO OBJECT

Allows an individual to prevent processing for purposes of:

▪ Processing based on legitimate interests or the performance of a task in the public

interest/exercise of official authority (including profiling).

▪ Direct marketing (including profiling).

▪ Processing for purposes of scientific/historical research and statistics.

5 INCIDENT

GDPR introduces a duty to report certain types of personal data breach to the relevant supervisory

authority. Where feasible Marico Marine will do this within 72 hours of becoming aware of the breach.

If the breach is likely to result in a high risk of adversely affecting individuals’ rights and freedoms,

Marico Marine will also inform those individuals without undue delay.

This policy will be updated to reflect the General Data Protection Regulation (GDPR) May 2018. Please

view the ICO’s website (https://ico.org.uk) which provides further details and guidance.

For help or advice on any data protection or freedom of information issues, please do not hesitate to

contact: The Data Protection Officer (DPO): André Cocuccio, UK Director.

Signed:

Name: André Cocuccio

Role: UK Director, Marico Marine

Date: 29 April 2021

Date to be reviewed: 30 April 2022

PRIVACY & DATA PROTECTION POLICY STATEMENT

Marine and Risk Consultants (Marico Marine) needs to gather, retain and use certain information about companies and individuals. These can include clients, suppliers, business contacts and other people the organisation has a business relationship with or may need to contact. This policy describes how this personal data is collected, handled and stored to meet the company’s data protection standards, and to comply with the law. The policy ensures that Marico Marine:

• Complies with General Data Protection Regulation (GDPR) and follows good practice;

• Protects the rights of clients and partners;

• Is open about how it stores and processes the data it holds;

• Protects itself from the risks of a data breach. Marico Marine holds and processes information which has been provided by you on the following basis:

• Project information

• Client and business contact details

• Recruitment details

• Accounts and Finance information

• Website browsing activity We will hold and process this information securely and indefinitely as required in the course of our business. You have the right to contact us in order to stop us using and processing your information, delete your information, or change the information we hold for you. We may contact you by post, email, telephone, where we have the relevant contact details, unless you have previously specified preferences in this regard. You can change your contact preferences at any time by contacting us. We do not and never will share your information with any third party except where we are compelled to by law or where you have given us express permission to do so. We also do not obtain any information from third parties.

SLAVERY & HUMAN TRAFFICKING STATEMENT (MODERN SLAVERY ACT 2015)

This statement is made pursuant to section 54 of the Modern Slavery Act 2015 and sets out the

steps that Marine and Risk Consultants Ltd (Marico) has taken and is continuing to take to ensure

that modern slavery or human trafficking is not taking place within our business or supply chain.

Modern slavery encompasses slavery, servitude, human trafficking and forced labour. Marico has a

zero tolerance to any form of modern slavery. We are committed to acting ethically and with

integrity and transparency in all business dealings and to putting effective systems and controls in

place to safeguard against any form of modern slavery taking place within the business or our supply

chain.

1.1 OUR BUSINESS

Marico is a company based at Marico House, Bramshaw, Southampton, UK. We provide marine and

risk consultancy services and equipment to Port Authorities and other marine organisations.

1.2 OUR POLICIES

We operate a number of internal policies to ensure that we are conducting business in an ethical

and transparent manner. These include:

• Ethical anti-Corruption policy. This sets out how our employees need to respect the

laws of the countries with whom they deal and take seriously any occurrences of

dishonesty;

• Anti-slavery policy. This policy sets out the organisation’s stance on modern slavery

and explains how employees can identify any instances of this;

• Procurement. Our Terms and Conditions which apply to and govern our Purchase

Orders state that our suppliers are required to adhere to our anti-slavery policy;

• Recruitment policy. We operate a robust recruitment policy, including conducting

eligibility to work in the UK checks for all employees to safeguard against human

trafficking or individuals being forced to work against their will;

• Whistleblowing policy. We operate a whistleblowing policy so that all employees

know that they can raise concerns about how colleagues are being treated, or

practices within our business or supply chain, without fear of reprisals; and

• Staff handbook. This handbook explains the manner in which we behave as an

organisation and how we expect our employees and suppliers to act.

1.3 TRAINING

We will conduct training for our procurement/buying teams if appropriate in order to ensure they

understand the signs of modern slavery and what to do if they suspect that it is taking place within

our supply chain.

1.4 APPROVAL FOR THIS STATEMENT

This statement was approved by the Director of Operations (UK):

Signed

André Cocuccio – UK Director

Date: 29 April 2021

Date to be Reviewed: 30 April 2022

EQUAL OPPORTUNITIES POLICY STATEMENT

Marico Marine is committed to encouraging equality and diversity among our workforce and eliminating

unlawful discrimination.

The aim is for our workforce to be truly representative of all sections of society and our customers, and for

each employee to feel respected and able to give their best.

Marico Marine, in providing goods and/or services and/or facilities, is also committed against unlawful

discrimination of customers or the public.

This policy’s purpose is to:

▪ provide equality, fairness and respect for all in our employment, whether temporary, part-time or

full-time;

▪ not unlawfully discriminate because of the Equality Act 2010 protected characteristics of age,

disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race

(including colour, nationality, and ethnic or national origin), religion or belief, sex (gender) and sexual

orientation; and

▪ oppose and avoid all forms of unlawful discrimination. This includes in pay and benefits, terms and

conditions of employment, dealing with grievances and discipline, dismissal, redundancy, leave for

parents, requests for flexible working, and selection for employment, promotion, training or other

developmental opportunities.

In meeting these commitments, Marico Marine will:

▪ encourage equality and diversity in the workplace as they are good practice and make business sense;

and

▪ create a working environment free of bullying, harassment, victimisation and unlawful discrimination,

promoting dignity and respect for all, and where individual differences and the contributions of all

staff are recognised and valued.

This commitment includes training managers and all other employees about their rights and

responsibilities under the equality policy. Responsibilities include staff conducting themselves to help

the organisation provide equal opportunities in employment, and prevent bullying, harassment,

victimisation and unlawful discrimination.

All staff should understand that they, as well as their employer, can be held liable for acts of bullying,

harassment, victimisation and unlawful discrimination, in the course of their employment, against

fellow employees, customers, suppliers and the public;

▪ Take seriously complaints of bullying, harassment, victimisation and unlawful discrimination by fellow

employees, customers, suppliers, visitors, the public and any others in the course of the

organisation’s work activities.

Such acts will be dealt with as misconduct under the organisation’s grievance and/or disciplinary

procedures, and any appropriate action will be taken. Particularly serious complaints could amount to

gross misconduct and lead to dismissal without notice.

Further, sexual harassment may amount to both an employment rights matter and a criminal matter,

such as in sexual assault allegations. In addition, harassment under the Protection from Harassment

Act 1997 – which is not limited to circumstances where harassment relates to a protected

characteristic – is a criminal offence;

▪ Make opportunities for training, development and progress available to all staff, who will be helped

and encouraged to develop their full potential, so their talents and resources can be fully utilised to

maximise the efficiency of the organisation;

▪ Make decisions concerning staff based on merit (apart from in any necessary and limited exemptions

and exceptions allowed under the Equality Act);

▪ Review employment practices and procedures when necessary to ensure fairness, and also update

them and the policy to take account of changes in the law; and

▪ Monitor the make-up of the workforce regarding information such as age, gender, ethnic background,

sexual orientation, religion or belief, and disability in encouraging equality and diversity, and in

meeting the aims and commitments set out in the equality policy.

Monitoring will also include assessing how the equality policy, and any sporting action plan, are

working in practice, reviewing them annually, and considering and taking action to address any issues.

This Equality & Diversity Policy is fully supported by senior management. Details of The Company’s grievance

and disciplinary policies and procedures can be found in the Marico Staff Handbook. This includes to whom an

employee should raise a grievance – usually their line manager. Use of the organisation’s grievance and/or

disciplinary procedures does not affect an employee’s right to make a claim to an employment tribunal within

three months of the alleged discrimination


Date: 29 April 2021


ETHICAL ANTI-CORRUPTION POLICY STATEMENT

Marico Marine (the Company) insists on honesty, integrity and fairness in all aspects of its business

and it expects the same of those it does business for and with.

• We observe all applicable laws and regulations of the countries in which we operate.

• Our employees are expected to act lawfully, in a professional manner and with the

utmost integrity in their dealings with our clients, competitors, suppliers, the

community and each other, striving at all times to enhance the reputation and

performance of the Company. They must respect the dignity and human rights of

colleagues and the people that we do business with. All new employees at the

Company must confirm that they have read the Quick Guide to the Bribery Act 2010

and guidance notes which are sent to them as part of their induction;

• All business transactions on behalf of the Company must be reflected accurately and

fairly in the accounts of the Company in accordance with established procedures

and be subject to audit;

• We avoid conflicts of interest in the services we provide to our clients. Our

employees do not accept or give gifts or hospitality of significant value in any form;

• Our employees must avoid conflicts of interest between their private financial

activities and their part in the conduct of the Company’s business;

• We take malpractice and dishonesty very seriously. Employees and any associated

third parties are encouraged to report any wrong doing by the Company or its

employees that falls short of our business policies and principles.

The Company will not tolerate any form of corruption or bribery. This policy applies to all the

Company's business dealings and transactions in all countries in which it or its subsidiaries and

associates operate. We will observe all applicable laws and regulations in the countries in which the

Company does business.

Signed


Date: 29 April 2021

Date to be Reviewed: 30 April 2022

HEALTH AND SAFETY POLICY STATEMENT

Marico Marine believes that accidents and illness at work are preventable, and that high standards

of health and safety management are of the utmost importance to the effectiveness, efficiency and

reputation of the company. Marico Marine is committed to protecting the health and safety of

employees, clients, contractors, visitors and the communities in which the company operates, both

in the UK and overseas.

In meeting these commitments, Marico Marine will:

• Comply with legal and other relevant requirements as pertinent to an office

environment;

• Maintain safe and healthy working conditions by identifying and mitigating health

and safety risks in the work place and arising from its work activities as pertinent to

an office environment;

• Consult with employees on matters affecting their health and safety;

• Provide and maintain equipment in a safe condition;

• Provide appropriate information, instruction and supervision for employees;

• Ensure all employees are adequately trained and are competent to do their assigned

tasks; and

• Review and revise this policy at regular intervals and following any significant

changes in legislation or circumstances.

ENVIRONMENTAL POLICY STATEMENT

Marine and Risk Consultants Limited (Marico Marine) is committed to minimising the impact of its

activities on the environment in which it operates, both on shore and afloat.

In meeting this commitment, Marico Marine will:

• Comply with legal and other relevant requirements as pertinent to an office

environment;

• Assess its activities in order to establish and minimise any adverse consequences for

the environment;

• Use appropriate machinery and power sources so as to minimise toxic and polluting

emissions into the atmosphere or water, as pertinent to an office environment;

• Strictly control the handling and use of ozone-depleting gases so as to minimise

adverse effects on the atmosphere as pertinent to an office environment;

• Minimise waste by evaluating operations and ensuring they are as efficient as

possible;

• Actively promote recycling internally (i.e. ink toners, computer equipment,

packaging materials);

• Use environmentally friendly and biodegradable cleaning products;

• Provide information, instruction and supervision for employees;

• Ensure all employees are adequately trained and are competent to do their assigned

tasks within the office; and

• Review and revise this policy at regular intervals and following any significant

changes in legislation or circumstances.


Date: 29 April 2021


CORPORATE SOCIAL RESPONSIBILITY POLICY

Marico Marine is committed to achieving the highest standards of service, delivery and employment practice whilst

ensuring equality of opportunity for all personnel within our workforce.

We achieve this through:

• Continuous business improvement in our performance and delivery of our services;

• Having due regard to efficiency, economy, effectiveness and equal opportunities;

• Acknowledging at all levels the value of each and every individual across our workforce;

• Actively working to make a meaningful difference for Marico, our clients and across the industries in which we

operate.

Marico Marine has adopted policies which support the development of a positive and inclusive working environment and

organisational culture where all employees have right to fair treatment, respect and continuous professional development.

In doing so, we aim to ensure that our employment practices secure equality of opportunity and that no prospective or

existing employee receives less favourable treatment as a result of their age, gender, marital status, ethnic origin, disability

or any other reasons which cannot be shown to be justified.

Such policies include:

• Policies in relation to equality, diversity, anti-bribery, anti-slavery, etc;

• Promotion of good workforce practices in delivery of services and contracts;

• Provision of an outstanding work environment based on the New Forest, England;

• Fair and contemporary employment terms and conditions for all employees;

• Flexible iniatives for staff assistance;

• A wide range of staff training and development opportunities; and

• A strong commitment to the continued professional development of all team members.

Signed:


Date: 29 April 2021


QUALITY POLICY STATEMENT

The Marine & Risk Consultants Limited quality policy is to achieve sustained, profitable growth by providing services which

consistently satisfy the needs and expectations of its customers.

This level of quality is achieved through the adoption of a system of procedures (processes) that reflect the competence of

the Company to existing customers, potential customers, and independent auditing authorities. The procedures can be

found on the server and consultants are issued with the updated procedures when produced. Marico procedures are

subject to annual review and all updates are distributed to the relevant staff. A robust audit programme, in tune with any

risk element, ensures that staff remain aware of and compliant with their relevant procedure(s).

To ensure company-wide consistency, QA approved forms and templates complement the procedures and these can be

found within the relevant folders in the QA area on the server.

Flexibility and the ability to deal, if necessary, with a client’s changing needs during a project phase is key to Marico’s

success in ensuring that a perfect solution is found each time for the client.

Feedback, via End of Project Audit and external Customer Satisfaction Survey, is actively sought at the termination of each

project, or annually for ongoing work, or if a project is not awarded to Marico. This feedback is recorded and analysed by

top management at regular intervals in order to continually seek improvement. Achievement of this policy involves all

staff, who are individually responsible for the quality of their work, resulting in a continually improving working

environment for all. This policy is provided and explained to each employee by the Director or Quality Manager.

To achieve and maintain the required level of assurance the Director retains responsibility for the Quality System with

routine operation controlled by the Quality Manager.

The policy of the Quality Assurance System is:

• To maintain an effective Quality Assurance System complying with International Standard ISO9001 (Quality

Systems);

• To achieve and maintain a level of quality which enhances the Company's reputation with customers which

includes the QA of all reports and proposals issued to clients;

• To ensure compliance with relevant statutory and safety requirements;

• To endeavour, at all times, to maximise customer satisfaction with the services provided by Marine & Risk

Consultants Limited;

• To comply with the relevant laws and codes of practice of the local place of work;

• To comply with the guidelines laid down in the Bribery Act 2010 which are encompassed in the Company’s Ethical

and Anti-Corruption Policy, a copy of which is issued to each member of staff;

• To maintain professional secrecy with respect to information gained from the work with clients, their partners

and suppliers; and

• To maintain a policy of equality within the work place.

Objectives are set annually to comply with quality policy.


Date: 29 April 2021


gdpr policy - marico marine

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